General Disclosures

Wealthfront Advisers LLC (“Wealthfront Advisers”) is an SEC-registered investment adviser. Wealthfront Brokerage LLC (”Wealthfront Brokerage”), member FINRA / SIPC, provides brokerage products and services. Wealthfront Software LLC (“Wealthfront Software”) offers a free software-based financial advice engine that delivers automated financial planning tools to help users achieve better outcomes.

Wealthfront Advisers, Wealthfront Brokerage, and Wealthfront Software are all wholly-owned subsidiaries of Wealthfront Corporation (“Wealthfront”). Wealthfront and its affiliates operate a website at www.Wealthfront.com (the "Site" (which includes our blog)) and a mobile application (the "App").

All product names, logos, and brands are property of their respective owners. Use of these names, logos, and brands is for identification purposes only, and does not imply endorsement or affiliation.

Wealthfront Advisers

Wealthfront Advisers provides investment advisory services only to investors who are advisory clients of Wealthfront Advisers ("Clients") pursuant to written advisory client agreements, which investors are urged to read and carefully consider in determining whether such agreements are suitable for their individual facts and circumstances. (Please refer to this website to review documents including but not limited to: ADV, Form CRS, and Client Agreements.). Wealthfront Advisers does not provide personalized financial planning, such as estate, tax, or retirement planning. Nothing on the Site or the App should be construed as a solicitation or offer, or recommendation, to buy or sell any security.

Past Performance Is No Guarantee Of Future Results, And Any Expected Returns Or Hypothetical Projections May Not Reflect Actual Future Performance. Furthermore, Past Returns May Reflect The Performance Of Assets For A Finite Time, Or During A Period Of Extreme Market Activity. All Investments Involve Risk And May Lose Money. There can be no assurance that an investment mix or any projected or actual performance shown on the Site or App will lead to the expected results shown or perform in any predictable or specific manner. It should not be assumed that investors will experience returns comparable to those shown or that any or all Clients actually experienced such returns.

In accounts in which Wealthfront Advisers employs its investment strategies, including portfolio rebalancing and tax-loss harvesting, high levels of trading may occur. High levels of trading could result in (a) bid-ask spread expense; (b) trade executions that may occur at prices beyond the bid-ask spread (if quantity demanded exceeds quantity available at the bid or ask); (c) trading that may adversely move prices, such that subsequent transactions occur at less favorable prices; (d) trading that may disqualify some dividends from qualified dividend treatment; (e) unfulfilled orders or portfolio drift, in the event that markets are disorderly or trading halts altogether; and (f) unforeseen trading errors.

If you transfer your outside account to an account managed by Wealthfront Advisers, we will apply our algorithms to sell your transferred account, seeking to minimize any potentially negative tax impact and optimizing for other factors, and invest the proceeds into a Wealthfront portfolio. If you transfer assets from one Wealthfront account to another Wealthfront account your transferred assets may also be liquidated by the software. Liquidating your transferred account may cause, among other things, realized capital gains or losses in specific securities, surrender fees, and redirection of declared dividends or distributions. You should also be aware that liquidating securities prior to transferring an account to be invested in a Wealthfront portfolio may subject you to the same risks.

Clients should be aware that in some limited instances it may be difficult or impossible to trade the Clients’ securities. This liquidity risk may be caused by numerous factors, including but not limited to: 1) extreme market volatility, 2) a decision by exchange participants to withhold some or all of their quoted market bids, 3) exchange technical issues or exchange closure, 4) delisted or halted securities, and/or 5) a position across Client accounts that is large relative to the average daily trading volume of the security.

Wealthfront Advisers' Process

Wealthfront Advisers' methodology is based on Modern Portfolio Theory, for which the Nobel Prize was awarded in 1990. It is considered state-of-the-art portfolio modeling, but is only one possible way to invest. Clients should be aware that Wealthfront Advisers’ process is based in part on a careful evaluation of past price performance and volatility in order to evaluate future probabilities. Although Wealthfront Advisers seeks multiple asset classes for its Clients in order to diversify portfolios, it is possible that different or unrelated asset classes may all exhibit similar price changes in similar directions. This correlation of price behavior may adversely affect a Client, and may become more acute in times of market upheaval or high volatility.

Client-Defined Portfolios

Wealthfront Advisers offers accounts in which Clients may request to purchase or sell specific securities or elect to customize the securities and allocations in their investment account(s).

Classic Portfolio

Wealthfront uses low cost, index-based exchange traded funds (ETFs) in its Classic Portfolio to represent the following asset classes: US Stocks Foreign, Developed Market Stocks, Emerging Market Stocks, Dividend Growth Stocks, US Bonds, US Corporate Bonds, Emerging Market Bonds, Municipal Bonds, Treasury Inflation-Protected Securities (TIPS), Real Estate, and Commodities. Clients are recommended a portfolio based on the results of a risk questionnaire, which evaluates their ability and willingness to take risk. Read more about the investment methodology in our whitepaper here.

Socially Responsible Investing Portfolio

Certain ETFs available to Wealthfront’s clients are labeled by Wealthfront as “Socially Responsible”. In order to be labeled as socially responsible, an ETF must meet at least one of the following criteria: (1) The ETF tracks an index marketed as seeking to adhere to socially responsible or ESG principles through the selection and weighting of its constituents (2) The ETF tracks an index which specifically excludes companies involved in environmentally destructive businesses such as oil and gas exploration and refining, thermal coal, oil sands, palm oil harvesting, or unsustainable production of forest products (3) The ETF tracks an index which favors companies, via the selection or weighting of its constituents, engaged in businesses related to: clean or renewable energy; electric vehicles or clean transportation; or sustainable agriculture and/or forestry (4) The ETF tracks an index which favors companies, via the selection or weighting of its constituents with policies and practices supporting of empowerment of women, minorities, or members of any disadvantaged class, or the inclusion of women, minorities, or members of any disadvantaged class in leadership positions. Clients are recommended a portfolio based on the results of a risk questionnaire, which evaluates their ability and willingness to take risk. Read more about the investment methodology in our SRI whitepaper here.

US Direct Indexing

US Direct Indexing requires a minimum of $100k and Clients authorize Wealthfront Advisers to effect transactions in their accounts in accordance with their elections. However, such Clients also understand and agree that Wealthfront Advisers retains full discretion over the securities and allocations in their portfolio. In certain situations, the securities and allocations in a Client’s portfolio may differ from securities and allocations elected by the Client. A lack of liquidity, market conditions, unavailable pricing, software failure, tax considerations, wash sale prevention, and other factors may prevent Wealthfront Advisers from effecting transactions in accordance with a Client’s specified election. Clients should note that ETF categorization and descriptions are not the views of Wealthfront Advisers, but of third-parties, including ETF issuers, made available by Wealthfront Advisers for your convenience. Clients should always read an ETF’s prospectus prior to making any investment decision.

Smart Beta

Smart Beta requires a minimum of $500k and blends five single-factor strategies (momentum, high profitability, high dividend yield, low market beta, and low volatility) with the cap-weighted market index to generate a modified index. This index then serves as the benchmark for our US Direct Indexing service, which seeks to maximize the quantity of harvested losses while minimizing the tracking error from the supplied benchmark. Read more about the methodology for Smart Beta in our whitepaper here.

The Wealthfront Risk Parity Fund

The Wealthfront Risk Parity Fund is managed by Wealthfront Strategies LLC (“Wealthfront Strategies”), an SEC registered investment adviser and a wholly owned subsidiary of Wealthfront Corporation. Wealthfront Strategies receives an annual management fee and acquired fund fees and expenses equal to 0.25% of the Fund's average daily net assets. Northern Lights Distributors, LLC, a Member of FINRA / SIPC, serves as the principal distributor for the Fund, and is not affiliated with Wealthfront Corporation or its affiliates.

Investors should carefully consider the investment objectives, risks, charges and expenses of the Wealthfront Risk Parity Fund. This and other important information about the Fund is contained in the prospectus, which can be obtained by calling toll free 877-910-4232. The prospectus should be read carefully before investing. For the full disclosures related to the Wealthfront Risk Parity Fund, please refer to the current prospectus, available here.

For more information regarding the risks of investing in the Fund, please see the Principal Investment Risks section of the Fund's prospectus. Past performance is no guarantee of future results.

ETF Disclosures

The securities employed in certain Client accounts include exchange-traded funds or other publicly registered funds ("ETFs"), which generally are registered investment companies under the Investment Company Act of 1940. Although Wealthfront Advisers believes its selection process identifies ETFs with high liquidity, low expenses, and low tracking error, Wealthfront Advisers’ selection process does not guarantee the quality of a particular ETF or that it will 1) be profitable, 2) properly track any comparable index, 3) trade in a liquid fashion, or 4) trade at or above its publicly-posted net asset value.

Wealthfront Advisers reserves the right to change at any time the selection of ETFs that it recommends if, in Wealthfront Advisers’ sole discretion, any ETF does not meet requirements for continued listing on the platform. Clients should be aware that changes in the selection of ETFs employed by Wealthfront Advisers’ investment management service may result in the sale of their existing holdings and may subject them to additional tax liability.

An ETF typically includes embedded expenses that may reduce its net asset value and therefore directly affect its performance and indirectly affect a Client’s portfolio performance or an index benchmark comparison. These embedded expenses may include management fees, custodian fees, and legal and accounting fees. ETF expenses may change from time to time at the sole discretion of the ETF issuer. Wealthfront Advisers discloses each ETF’s current information, including expenses, on the Site and App. ETF tracking error and expenses may vary.

Furthermore, ETF performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because 1) the ETF incurs expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF.

Certain ETF strategies may from time to time include fixed income, commodities, foreign securities, American Depositary Receipts, or other securities for which expenses could be higher than otherwise charged for exchange-traded equity securities, and for which market quotations or valuation may be limited or inaccurate.

Performance Disclosures

Performance information is presented net of all management fees and expenses, unless marked otherwise. Commissions are not considered since Clients on the Wealthfront Advisers’ platform are not charged trading commissions. For all time periods, the performance information includes the reinvestment of dividends and interest unless otherwise noted.

Any comparison to traditional financial advisors is based on an evaluation of average fees and returns. Actual results may be different for each investor and there can be no guarantee of enhanced returns due to additional diversification, ETF selection, or the use of Wealthfront Advisers’ investment management service.

Investors who become Clients may experience different results than what is reflected in available hypothetical results. There is a potential for loss, as well as gain, that may not be reflected in hypothetical information. The hypothetical performance results shown do not represent the results of actual trading using Client assets but were achieved by means of the retroactive application of a model designed with the benefit of hindsight. Investors should carefully review all additional information presented by Wealthfront Advisers as part of any hypothetical comparison.

Any comparisons to indices are provided for illustrative purposes only. An index is a broadly diversified, unmanaged group of securities, which may include only large capitalization companies or companies of a certain size. Broadly based indices may be shown only as an indication of the general performance of the financial markets during the periods indicated. Because of the differences between the client allocations and any indices shown, Wealthfront Advisers cautions investors that no index is directly comparable to the performance shown since each index has its own unique results and volatility, and such indices, if shown, should not be relied upon as an accurate comparison.

The return, composite, and performance information shown on the Site or App uses or includes information compiled from third-party sources, including independent market quotations and index information. Wealthfront Advisers believes the third-party information comes from reliable sources, but Wealthfront Advisers does not guarantee the accuracy of the Site or App information and may receive incorrect information from third-party providers. Unless otherwise indicated, the information on the Site or App has been prepared by Wealthfront Advisers and has not been reviewed, compiled or audited by any independent third-party or public accountant.

Fee and Account Disclosures

Recommendations and fees may vary for each Client. Advisory fees for a fully discretionary account are calculated for each Client based upon the amount of assets being managed for that Client (as detailed further in Wealthfront Advisers’ Form ADV Part 2).

Wealthfront Advisers does not make any representations regarding the execution quality of orders placed with our executing broker-dealer partner. However, Wealthfront Advisers does monitor the execution quality of transactions to ensure that Clients receive the best overall trade execution pursuant to regulatory requirements.

Description of "Free." Certain ETF products, offered through Wealthfront Advisers, may be free of commissions; however, management and/or other fees may be charged for investment products managed by outside companies, which are unaffiliated entities of Wealthfront Advisers.

Portfolio Line of Credit

Portfolio Line of Credit is a margin lending product offered by Wealthfront Brokerage exclusively to Clients of Wealthfront Advisers. Margin lending can add to your overall investment risk, and you should consider the risks and benefits specific to margin when evaluating your overall financial strategy. Learn more about these risks in the Margin Handbook.

Tax and Tax-Loss Harvesting Disclosures

Wealthfront Advisers does not represent in any manner that the tax consequences described as part of its Tax-Loss Harvesting service will be achieved or that Wealthfront Advisers’ Tax-Loss Harvesting service, or any of its products and/or services, will result in any particular tax consequences. The tax consequences of its Tax-Loss Harvesting service and other strategies that Wealthfront Advisers may pursue are complex and uncertain and may be challenged by the IRS. Wealthfront does not provide tax advice to Clients. The information with regard to this service was not prepared to be used, and cannot be relied upon, by any investor to avoid penalties or interest. In addition, the performance of the alternate securities purchased through its Tax-Loss Harvesting service may be better or worse than the performance of the securities that are sold for tax-loss harvesting purposes.

Wealthfront Advisers’ investment strategies, including portfolio rebalancing and tax-loss harvesting, can lead to high levels of trading. High levels of trading could result in (a) bid-ask spread expense; (b) trade executions that may occur at prices beyond the bid ask spread (if quantity demanded exceeds quantity available at the bid or ask); (c) trading that may adversely move prices, such that subsequent transactions occur at worse prices; (d) trading that may disqualify some dividends from qualified dividend treatment; (e) unfulfilled orders or portfolio drift, in the event that markets are disorderly or trading halts altogether; and (f) unforeseen trading errors. The performance of the new securities purchased through its Tax-Loss Harvesting service may be better or worse than the performance of the securities that are sold for tax-loss harvesting purposes.

Clients should confer with their personal tax advisors regarding the tax consequences of investing with Wealthfront Advisers and engaging in its Tax-Loss Harvesting service, based on their particular circumstances. Clients and their personal tax advisors are responsible for how the transactions conducted in an account are reported to the IRS or any other taxing authority on the Client’s personal tax returns. Wealthfront Advisers assumes no responsibility for the tax consequences to any Client of any transaction.

The ability to utilize losses harvested through the strategy will depend upon the recognition of capital gains in the same or a future tax period, and in addition may be subject to limitations under applicable tax laws. Losses harvested through the strategy that are not utilized in the tax period when recognized (e.g., because of insufficient capital gains and/or significant capital loss carryforwards), generally may be carried forward to offset future capital gains, if any. Except as set forth below, Wealthfront Advisers will monitor only a Client’s accounts at Wealthfront Advisers to determine if there are unrealized losses for purposes of determining whether to harvest such losses. Transactions outside of such accounts may affect whether a loss is successfully harvested and, if so, whether that loss is usable by the Client in the most efficient manner. The effectiveness of its Tax-Loss Harvesting strategy to reduce the tax liability of the Client will depend on the Client’s entire tax and investment profile, including purchases and dispositions in a Client’s accounts outside of Wealthfront Advisers and type of investments (e.g., taxable or nontaxable) or holding period (e.g., short-term or long-term).

The Client is responsible for monitoring the accounts of the Client and the Client’s spouse, if any, that are held outside of Wealthfront Advisers to ensure that transactions in the same security or a substantially identical security do not create a “wash sale.” A wash sale is the sale at a loss and purchase of the same security or substantially identical security over a period of 61 calendar days: the day of the sale, the 30 days before the sale, and the 30 days after the sale. If a wash sale transaction occurs, the IRS may not allow or defer the loss for current tax reporting purposes. Wash sales can occur even if the securities are sold and then bought in different accounts. Therefore, Wealthfront Advisers may lack visibility to certain wash sales, should they occur as a result of external or unlinked accounts, and therefore Wealthfront Advisers may not be able to provide notice of such wash sales in advance of the Client's receipt of the IRS Form 1099. The effectiveness of the tax-loss harvesting strategy to reduce the tax liability of the Client will depend on the Client’s entire tax and investment profile, including purchases and dispositions in a Client’s (or Client’s spouse’s) accounts outside of Wealthfront Advisers and type of investments (e.g., taxable or nontaxable) or holding period (e.g., short-term or long-term). Except as set forth below, Wealthfront Advisers will monitor only a Client’s (or Client’s spouse’s) accounts at Wealthfront Advisers to determine if there are unrealized losses for purposes of determining whether to harvest such losses. Transactions outside of such accounts may affect whether a loss is successfully harvested and, if so, whether that loss is usable by the Client in the most efficient manner. A Client may also request that Wealthfront Advisers monitor the Client’s spouse’s accounts or their IRA accounts at Wealthfront Advisers to avoid the wash sale disallowance rule. A Client may request spousal monitoring online or by calling Wealthfront Advisers at 844.995.8437. If Wealthfront Advisers is monitoring multiple accounts to avoid the wash sale disallowance rule, the first taxable account to trade a security will block the other account(s) from trading in that same security for 30 days.

Cash Account

Wealthfront Brokerage establishes and carries accounts for Clients to hold funds for the purpose of investing and records transactions pursuant to Client discretion and instructions (a “Cash Account”). Neither Wealthfront Brokerage nor its affiliates is a bank. Checking features for a Cash Account are subject to identity verification by Green Dot Bank. The Wealthfront Cash Account Visa® Debit Card is optional and must be requested, and it is issued by Green Dot Bank, Member FDIC, pursuant to a license from Visa U.S.A. Inc. Visa is a registered trademark of Visa International Service Association. Green Dot Bank operates under the following registered trade names: GO2bank, GoBank, Green Dot Bank, and Bonneville Bank. All of these registered trade names are used by, and refer to, a single FDIC-insured bank, Green Dot Bank. Deposits under any of these trade names are deposits with Green Dot Bank and are aggregated for deposit insurance coverage. Wealthfront products and services are not provided by Green Dot Bank. Green Dot is a registered trademark of Green Dot Corporation. All rights reserved.

Early availability of a direct deposit depends on timing of payor’s payment instructions and fraud prevention restrictions may apply. As such, the availability or timing of early direct deposit may vary from pay period to pay period. Interest does not begin accruing until funds arrive at the program banks, which may take up to one business day.

Other fees apply to the checking features. Fee-free ATM access applies to in-network ATMs only. For out-of-network ATMs and bank tellers a $2.50 fee will apply, plus any additional fee that the owner or bank may charge. Other eligibility requirements for mobile check deposit and to send a check may apply. Please see the Deposit Account Agreement for details.

Apple Pay, Face ID, and Touch ID are trademarks of Apple Inc. Google Pay is a trademark of Google LLC.

The Annual Percentage Yield (APY) for the Cash Account is as of a specific date, and may change at any time. The APY for the Wealthfront Cash Account represents the weighted average of the APY on the aggregate deposit balances of all clients at the program banks. Deposit balances are not allocated equally among the participating program banks. Cash Account is offered by Wealthfront Brokerage. Wealthfront Brokerage conveys Cash Account funds to depository institutions that accept and maintain such deposits. The cash balance in the Cash Account is swept to one or more banks (the “Program Banks”) where it earns a variable rate of interest and is eligible for FDIC insurance. FDIC insurance is not provided until the funds arrive at the Program Banks. While funds are at Wealthfront, before they are swept to the program banks, they are subject to SIPC’s protection limit of $250,000 for cash. FDIC insurance coverage is limited to $250,000 per qualified customer account per banking institution. Wealthfront Brokerage uses more than one Program Bank to ensure FDIC coverage of up to $2 million for your cash deposits. For more information on FDIC insurance coverage, please visit www.FDIC.gov. Customers are responsible for monitoring their total assets at each of the Program Banks to determine the extent of available FDIC insurance coverage in accordance with FDIC rules. The deposits at Program Banks are not covered by SIPC.

Social Media and Testimonials

All statements made via social media sites sponsored or maintained by Wealthfront Software and its affiliates are not intended as investment, tax, or legal advice. Wealthfront Software and its affiliates are not responsible for, and do not endorse, the content by other users or followers of the social media sites sponsored or maintained by Wealthfront Software or its affiliates. Wealthfront Software and its affiliates are also not responsible for the terms of use or privacy or security policies of any social media sites, and you use such sites at your own risk. Wealthfront Software and its affiliates reserve all rights to block any user or follower who posts, tweets, or retweets content that is deemed inappropriate or offensive, or content that constitutes spam, a testimonial, advice, a recommendation, or an advertisement for securities, products, or services, or that is otherwise promotional in nature. Wealthfront Software and its affiliates also reserve all rights to block users or followers whose posts, tweets, or retweets contain offensive or inappropriate content or serve as promotional sites. Any opinions expressed by our users or followers are those of the persons submitting the comments and do not represent the views of Wealthfront Software or its affiliates.

Testimonials may not be representative of the experience of other Clients. Testimonials are not a guarantee of future performance or success.

Financial Planning

All information provided by Wealthfront Software’s financial planning tool is for illustrative purposes only, and you should not rely on such information as the primary basis of your investment, financial, or tax planning decisions. No representations, warranties or guarantees are made as to the accuracy of any estimates or calculations provided by the financial tool.

Wealthfront 529 College Savings Plan

The Wealthfront 529 College Savings Plan (the "Plan") is administered by the Board of Trustees of the College Savings Plans of Nevada (the “Board”), chaired by the Nevada State Treasurer. Ascensus College Savings Recordkeeping Services, LLC (“ACSR”) serves as the Program Manager of the Plan. Wealthfront Advisers serves as the investment adviser to the Plan. Wealthfront Brokerage serves as the distributor and the underwriter of the Plan. The Bank of New York Mellon Corporation (“Bank of New York Mellon”) is the Plan’s custodian. As such, Bank of New York Mellon is responsible for maintaining the Plan’s assets.

Before you invest, consider whether your or the beneficiary’s home state offers any state tax or other state benefits such as financial aid, scholarship funds, or protection from creditors that are only available for investments in that state’s qualified tuition program. You also should consult your financial, tax, or other advisor to learn more about how state-based benefits (or any limitations) would apply to your specific circumstances. You also may wish to directly contact your home state’s 529 plan(s), or any other 529 plan, to learn more about those plans’ features, benefits, and limitations. State-based benefits should be one of many appropriately weighted factors to be considered when making an investment decision. Earnings on nonqualified withdrawals are subject to federal income tax and may be subject to a 10 percent federal tax penalty, as well as state and local income taxes. The availability of tax and other benefits may be contingent on meeting other requirements.

For more information about the Plan, download the Plan Description and Participation Agreement or request one by calling 844-995-8437 or emailing support@wealthfront.com. Investment objectives, risks, charges, expenses, and other important information are included in the Plan Description and Participation Agreement; please read and consider it carefully before investing. An investment in the Plan is not insured or guaranteed by the FDIC or any federal or state government or agency. You could lose all or portion of your investment.